Fill and Sign the Innkeepers Liability Pennsylvania Form

1 23456789 10111213141516171819202122232425 262728 - 1 - [ INSERT CAPTION ] COMPLAINT (NEGLIGENCE-INNKEEPER LIABILITY-CRIMINAL ACTIVITY) COMES NOW the Plaintiff(s), , by counsel, and for his/her Complaint against the Defendant(s), , alleges and states: I. THE PARTIES 1. The Plaintiff(s), , (hereinafter referred to as Plaintiff), is an adult citizen of County, State of , and resides at 123 Main Street, in the City of Small Town. 2. The Defendant, , (hereinafter referred to as Defendant One), is a corporation incorporated under the laws of the State of , whose principal place of business is at 321 Elm Street, in the City of Small Town, and is subject to service of process by and through its registered agent: [insert registered agent’s name and address]. II. THE FACTS 3. Plaintiff was a business invitee and registered guest at Defendant’s hotel. On , 20__, at approximately o’clock .m., Plaintiff left her hotel room and walked through the hotel parking lot to some nearby shops. When Plaintiff was returning to the hotel she was assaulted, battered and forcibly raped by an unknown assailant in the hotel parking lot. 4. The Defendant had actual or constructive notice that criminal activity of the kind complained of herein and similar criminal activity had previously occurred at Defendant’s hotel and that the assault, battery and rape of Plaintiff was reasonably foreseeable. At the aforesaid time and place, the Defendant did not employee any 1 23456789 10111213141516171819202122232425 262728 - 2 - security staff or post any warnings to its business invitees as to the lack of security staff on the premises, thereby creating a dangerous and hazardous condition on the premises III. THE CLAIMS 5. Defendant a duty to maintain its business premises in a reasonably safe and secure condition a duty to take steps reasonably calculated to remove the aforesaid hazardous and dangerous condition. The Defendant also had a duty to warn its business invitees of the aforesaid dangerous and hazardous condition. 1. The Defendant breached its duties delineated hereinabove by failing to employ a security staff when Defendant knew, or should have known, from the aforesaid prior criminal activity occurring on its premises, that 6. The Defendant breached its duties delineated hereinabove proximately causing Plaintiff to suffer the following damages: [insert types of damages, e.g., severe and permanent personal injuries; past, present and future pain and suffering; past, present and future mental anguish and other emotional damages; temporary and/or permanent disability; past, present and future medical and/or psychological/psychiatric expenses and costs; past and present lost wages; lost wage earning capacity; etc.]. IV. DEMAND FOR RELIEF 7. The Plaintiff prays for the following relief: (1) Trial by jury; (2) Judgment for Plaintiff and against the Defendant; (3) An award of damages which will fully and fairly compensate Plaintiff for [insert types of damages, e.g., [insert types of damages, e.g., severe and permanent personal injuries; past, present and future pain and suffering; past, present and future mental anguish and other emotional damages; temporary and/or permanent 1 23456789 10111213141516171819202122232425 262728 - 3 - disability; past, present and future medical and/or psychological/psychiatric expenses and costs; past and present lost wages; lost wage earning capacity; etc.]. (4) Such other and further relief deemed just and proper in the premises.